Tom King’s CRM Plus --
Ruminations on "cultural resource management," environmental impact assessment, and related esoteric topics, by a curmudgeon who seldom has anything good to say about anything.

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Tuesday, March 15, 2011

Consultants: Finding a Donut Hole May Not Be In Your Client’s Best Interests

I’ve recently found myself reviewing a number of archaeological survey reports (usually mis-titled “cultural resource inventories”) prepared by consulting firms for agencies that propose to build things with the potential for churning up archaeological sites. I’ve been dismayed, though not especially surprised, to find a pattern of reportage that I have to think is designed to conceal potential archaeological problems and allow the consultants’ clients to find that their projects will have no effect on archaeological sites.

For example, in one case from southern California, construction is proposed on a bluff overlooking the ocean – a classic location for prehistoric occupation. The consultants’ report, in the section on “previous archaeological investigations,” presents a table showing all the archaeological sites previously recorded within a mile or so of the project location. A dozen or more – ranging from small deposits of mollusk shells, flakes, and fire-cracked rock to a large village/burial complex that’s been the source of considerable controversy over the years – lie within about 2-300 meters of the project location. The project location is completely covered by mid-20th century buildings, parking lots, sidewalks and landscaping. The consultants’ archaeologists duly walked the sidewalks and reported finding nothing. So, they reported, there’s nothing there and a finding of “no historic properties affected” is appropriate under Section 106. They say nothing about the topographic/environmental predictors of probable site location, and the fact that sites crowd the project location on every hand does not, it seems, suggest anything to them. And they evince no knowledge of the many cases in which more or less intact archaeological deposits and things like cemeteries have been found under modern buildings and landscaping.

In another case, from Oregon, the project site is a golf course on a riverbank, proposed for conversion to housing. The consultants’ report has a section on “ethnography” that is so general it fails to mention that tribes in the area tended to set up villages on riverbanks. In its section on “previous archaeological investigations” it reports one site, thought to have a lot of housepits and to be particularly important in understanding local prehistory, on the riverbank east of a sewer treatment plant; it fails to note that the proposed construction site is on the same riverbank, east of the same plant. From the project location map it appears that it’s maybe 150 to 200 meters from the sewage plant to the project site, so presumably the recorded site is somewhere on that intervening stretch of riverbank. Another possibly important site is reported just to the east; a bit of digging through the report and comparing it with Mapquest street maps reveals that it’s probably across the river from the project site, though the report doesn’t make this clear.

The Oregon project site, being a golf course, was a little more accessible than the California site, though its surface was obscured by turf. So the archaeologists walked transects across it and dug five or six test holes. In these they found a very light scatter of both prehistoric (flakes) and historic (bottle glass, etc.) artifacts. On the strength of this relatively negative data, they conclude that there’s nothing there.

Now, it may be that in both cases there really is nothing there, and undoubtedly it made the client happy in each case to learn that there were no archaeological impediments to the proposed project. The trouble, of course, is that this clean bill of health is not necessarily truthful. Prehistoric people, in my experience anyhow, were no respecters of site boundaries as defined by archaeologists (“No, no, Big Eagle, you can’t bury grandma over there; that’s outside the boundaries of site BS-2397!”). The presence of a “site” as defined by archaeologists simply means that people did stuff in the general area that produced something on that specific location that archaeologists can recognize. They may have done lots of other things in the broader area that archaeologists can’t recognize, or can’t recognize as well as they can other things. Burying dead people is one of those things. So the fact that your project footprint ju-u-ust misses the archaeologist-defined boundary of site BS-2397 doesn’t mean you’re not going to find grandma – maybe lots of grandmas – buried there. Or other things. And if the client doesn’t find out about those possible grandmas from your report, he or she may very well find out about them when they come up in a power shovel’s bucket. And living people start throwing things and seeking injunctions.

So, however much the client may want it, a determination that there’s nothing to worry about in a project area may not be in the client’s best interests. Such a determination can lull the client into thinking that all’s well, that he has nothing to worry about. Which is fine if it’s true, but a real problem if it’s not. And if there’s evidence that it’s not, and a consultant effectively covers it up, the consultant is setting the client up for a last-minute discovery situation that can be costly and embarrassing.

The reason to do background research in contract archaeology is not to find donut holes in which things can be built, but to make overall sense of what’s found in the transects fieldworkers walk and the test pits they dig. Contract archaeologists ought to take the results of background research, put them together with first-hand field observations, and give the client as realistic picture as possible of what archaeological problems his or her project may face. In the two cases I’ve outlined above, it seems obvious to me from the combination of topographic/environmental, ethnographic and archaeological data that the project sites may contain significant archaeological resources, and ought to be treated accordingly. My client may not be happy to have this advice from me, but he or she will be a lot less happy with a multi-million dollar work stoppage at the eleventh hour, and just may wonder why I didn’t mention the possibility early enough to let him or her do something about it.

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Welcome to Tom King's CRM Plus

Welcome to my blog on topics related to "cultural resource management," whatever that may mean to you or me. I hope you find some interest in what you read here, that you'll add your own contributions, and that you'll encourage others to have a look. Thanks!

About Me

Thomas F. King holds a PhD in anthropology from the University of California Riverside (1976), and has worked since the 1960s in the evolving fields of research and management variously referred to as heritage, cultural resource management, and historic preservation. He is particularly known for his work with Section 106 of the U.S. National Historic Preservation Act, and with indigenous and other traditional cultural places.

King is the author and editor of ten textbooks and tradebooks (See http://www.amazon.com/Thomas-F.-King/e/B001IU2RWK/ref=sr_tc_2_0?qid=1353864454&sr=1-2-ent) as well as scores of journal articles, popular articles, and internet offerings on heritage topics.His career includes the conduct of archaeological research in California and the Micronesian islands, management of academy-based and private cultural resource consulting organizations, helping establish government historic preservation systems in the freely associated states of Micronesia, oversight of U.S. government project review for the federal government’s Advisory Council on Historic Preservation, service as a litigant and expert witness in heritage-related lawsuits, and extensive work as a consultant and educator in heritage-related topics. He is the co-author of the U.S. National Park Service's government-wide guidance on "traditional cultural properties" (TCPs; see http://www.nps.gov/nr/publications/bulletins/pdfs/nrb38.pdf). He occasionally teaches short classes about historic preservation project review, traditional cultural places, and consultation with indigenous groups, and consults and writes as TFKing PhD LLC. Current major clients include several American Indian tribes and the U.S. Department of Veterans Affairs.